A letter from merlinux to Roskomandzor: Regarding registration of Delta Chat provided services in Russia with the following key content: 1) You fail to reference relevant International Law that would give you the authority to request any interaction from us as an organization residing within the legal framework of the European Union. If you don’t reference any international law or treaty, you are required to direct your queries to the german foreign ministry instead, which in turn would get in contact with us. 2) Even if your request was grounded in international law, merlinux is not an „ICO“ or „Information Communication Organizer“ as defined in Section 10.1 of 149-FZ. In particular, we maintain that this base assumption stated in your letter is not correct: „According to the results of the analysis the information resource delta.chat <https://delta.chat/> , the owner of which is a foreign organization merlinux GmbH, was found to have the capability to receive, transmit, deliver and (or) process electronic messages of Internet users.“ Unlike Telegram or Whatsapp, the information resource „delta.chat“ does not have the ability to receive, transmit, deliver or process electronic messages. All users of our e-mail client apps choose electronic message processors („e-mail servers“) sovereignly themselves, without our knowledge and without sending their messages through a central server like it happens with Telegram or Whatsapp.
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